Service Tax on R&D and Consultancy under RCM: CESTAT sets aside Extended Limitation due to Lack of Willful Suppression

The CESTAT has set aside an extended limitation for service tax on R&D and consultancy under Reverse Charge Mechanism (RCM) due to a lack of willful suppression. The tribunal found that the revenue department failed to establish that the taxpayer had intentionally suppressed information. This ruling emphasizes the importance of proving willful suppression to invoke extended limitation periods. The decision provides relief to taxpayers facing allegations of service tax evasion. The ruling reinforces the need for thorough investigations by revenue authorities.